A1.1 Multi-tenant service providers protect and separate all customer environments and data.
This requirement focuses on ensuring that multi-tenant service providers implement proper logical separation between customer environments. It ensures that providers protect customer data by preventing unauthorized access between environments and implementing controls to maintain separation.
Sub-requirements
- A1.1.1 : Logical separation is implemented as follows:
- A1.1.2 : Controls are implemented such that each customer only has permission to access its own cardholder data and CDE.
- A1.1.3 : Controls are implemented such that each customer can only access resources allocated to them.
- A1.1.4 : The effectiveness of logical separation controls used to separate customer environments is confirmed at least once every six months via penetration testing.
A1.1. Multi-Tenant Environment Isolation Controls
Ensure secure isolation of customer environments in shared infrastructure to prevent unauthorized access between tenants.
Control Types
Key Risks
Frequently Asked Questions
What defines a multi-tenant service provider under Appendix A1?
Entities offering shared services where customers share system resources (servers, apps, databases). Excludes co-location providers renting only physical space/bandwidth.
What documentation demonstrates environment isolation?
Required: 1) Network segmentation diagrams, 2) Hypervisor configuration reports, 3) Tenant access control matrices, 4) Penetration test results validating isolation.
How are responsibilities divided between provider and customer?
Formal agreements must define: 1) Shared vs dedicated controls, 2) Compliance validation scope, 3) Incident response duties. Reference PCI DSS Requirements 12.8-12.9.
What virtualization safeguards are required?
Implement: 1) Hypervisor hardening to CIS benchmarks, 2) VM escape protection mechanisms, 3) Storage encryption per tenant, 4) Network microsegmentation.
How often must isolation controls be validated?
**Quarterly** automated scans + **annual** penetration tests. Cloud environments require continuous configuration monitoring.
Common QSA Questions
Show evidence of cross-tenant penetration testing
2025-Q1 report used Metasploit to simulate VM escapes across 450 hosts. Results: 0 successful breaches. Remediated 3 high-risk hypervisor configs.
Demonstrate cryptographic tenant data segregation
We use AWS KMS customer-managed keys with IAM boundary policies. Evidence includes CloudTrail logs showing zero cross-tenant key access.
Provide shared responsibility agreements for SaaS customers
Contracts specify: 1) Provider manages VPC/VLAN segregation, 2) Customers handle app-layer controls, 3) Joint patching SLAs. Validated through CSA STAR reports.
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